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United States securities and exchange commission logo
May 6, 2020
Derek N. Yung
Chief Financial Officer
eHealth, Inc.
2625 Augustine Drive
Second Floor
Santa Clara, California 95054
Re:eHealth, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed March 2, 2020
File No. 001-33071
Dear Mr. Yung:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within 10 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Member Acquisition, page 50
1.In the footnotes to the table on page 51 you describe how you calculate the variable cost
per member presented in the table.  You disclose in each instance that the denominator is a
derived metric and describe how you calculated that divisor, but do not appear to disclose
the rationale behind the computation.  For each footnote in the table on page 51, please
tell us why you calculate the divisor the way you do.  In your response address each
component, and tell us why some individual components themselves are divided by either
three or four.  In addition, tell us your consideration for disclosing this information in your
filing or tell us where you disclose it.
Notes to Consolidated Financial Statements

 FirstName LastNameDerek N. Yung
 Comapany NameeHealth, Inc.
 May 6, 2020 Page 2
 FirstName LastNameDerek N. Yung
eHealth, Inc.
May 6, 2020
Page 2
Note 1 - Summary of Business and Significant Accounting Policies
Commission Revenue, page 80
2.You disclose here that health insurance carriers are your customers yet you disclose or
imply throughout your filing that the policyholders are your customers.  In this regard, for
example, on page 5 you indicate that you actively market various products to your
“Medicare-eligible customers” and to your “individual and family and small business
customers” and in your revenue recognition policy note on page 80 you discuss your
customer care centers which appear to be accessed by policyholders.  Please tell us how
the identification of policyholders as customers is consistent with your determination for
accounting purposes that the health insurance carriers are your customers.  In your
response, tell us how this apparent discrepancy is either meaningful to investors or, at a
minimum, not confusing.

Note 2 - Revenue
Revenue Recognition Based on Estimated Constrained LTV, page 85
3.On page 86 you disclose that you had sufficient additional information with respect to
increases in LTVs and estimates of future cash collections related to prior period cohorts
to recognize adjustment revenue related to these prior period cohorts in 2019.  You then
disclose that you recognized $50.8 million of adjustment revenue for Medicare Advantage
plans during the fourth quarter of 2019.  Please address the following:
•Tell us what additional information surfaced in the fourth quarter of 2019 prompting
recognition of additional revenue in that quarter.
•Tell us what enhancements you made to your Medicare Advantage LTV estimation
models in the fourth quarter of 2019 that provide greater statistical certainty on
expected cash collections.  Tell us why you made these enhancements.
•Tell us what role, if any, Mr. Robert Hurley took in your revenue recognition
practices, in general, and the enhancements identified in the preceding bullet, in
particular.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Mark Brunhofer at (202) 551-3638 or Sharon Blume at (202) 551-
3474 with any questions.
Sincerely,
Division of Corporation Finance

 FirstName LastNameDerek N. Yung
 Comapany NameeHealth, Inc.
 May 6, 2020 Page 3
 FirstName LastName
Derek N. Yung
eHealth, Inc.
May 6, 2020
Page 3
Office of Finance